https://www.taxtmi.com/caselaws?id=461581 Salary income of a non-resident was examined for Indian taxability under section 5(2)(a) and the India-USA tax treaty, with treaty relief claimed on the basis that services were rendered outside India. The tax authorities had not reviewed the Tax Residency Certificate or supporting evidence on residency, place of work, and stay outside India, so the record was insufficient to decide treaty entitlement or domestic taxability conclusively. The matter was therefore restored for fresh adjudication, with the assessee allowed to produce the Tax Residency Certificate and other relevant material. en-us Mon, 25 Sep 2023 00:00:00 +0530 Mon, 14 Apr 2025 19:03:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461581 Salary income of a non-resident was examined for Indian taxability under section 5(2)(a) and the India-USA tax treaty, with treaty relief claimed on the basis that services were rendered outside India. The tax authorities had not reviewed the Tax Residency Certificate or supporting evidence on residency, place of work, and stay outside India, so the record was insufficient to decide treaty entitlement or domestic taxability conclusively. The matter was therefore restored for fresh adjudication, with the assessee allowed to produce the Tax Residency Certificate and other relevant material. Case-Laws Income Tax Mon, 25 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461581